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Supreme Court of India 2022-04-25 allowed

Maniben Maganbhai Bhariya vs District Development Officer Dahod & Ors

Bench: 2 — Rastogi, J., Abhay S. Oka, J.

In Brief

This case addresses whether Anganwadi workers and helpers—who provide childcare, nutrition, health services, and pre-school education through government centres—are entitled to gratuity under the Payment of Gratuity Act, 1972. The Supreme Court held that they are. Despite initially being characterized as voluntary part-time workers, the Court found that: (1) Anganwadi centres constitute 'establishments' under the Act; (2) the honorarium paid is 'wages' under the Act's definition; and (3) workers are 'employees' entitled to statutory benefits. The Court emphasized that Anganwadi workers perform crucial statutory duties for child nutrition, health, and education, making them eligible for gratuity and 10% simple interest on overdue amounts, with implementation to be completed within three months.

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Constitutional Law Social Security Law Labour Law Gratuity Anganwadi Workers Welfare Legislation Employment Law Women's Rights Child Development Statutory Interpretation

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